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At all times relevant to this Information, unless otherwise indicated:

The Defendant

1. The defendant LEONARD WADLER resided in Roslyn, New York. The defendant
LEONARD WADLER was a real estate speculator doing business in Brooklyn,
New York. At various times the defendant LEONARD WADLER was the owner
of Homestead Equities, Inc., located in Roslyn, New York.

Foreclosure Proceedings

2. In Kings County, New York, foreclosure proceedings were initiated
by the mortgage holder (generally a bank) suing the property owner for
defaulting on the mortgage loan and seeking to foreclose on the property
that secured the loan. When a judgment was rendered for a mortgage holder,
the amount generally included, among other things, the remaining balance
on the loan secured by the mortgage, interest, and penalties.

3. Once a mortgage holder obtained a judgment, the judge presiding
over the foreclosure proceeding would appoint a Referee to conduct a
sale of the property by public auction. The Referee was responsible
for providing the notice required by New York state law that there would
be a foreclosure auction on the date and time specified in the notice.
The Referee then held the public foreclosure auction. The foreclosure
auctions were usually held at the Kings County Courthouse, located on
Adams Street in Brooklyn, New York.

4. The bidding at a public foreclosure auction typically opened at
the mortgage holder's "upset price." The upset price was sometimes
the amount of the judgment obtained by the mortgage holder against the
property owner, but was often less, depending on market conditions or
the condition of the property. The Referee sought the highest price
possible at the public foreclosure auction by soliciting open and competitive
bidding from potential purchasers and selecting the highest bid as the
price at which to sell the property.

5. Immediately after the auction, the highest bidder paid a 10% deposit
to the Referee by cashier's or certified check. The Referee and the
highest bidder then completed the "Terms of Sale." The Terms
of Sale included, among other things, the property's address, the date
of the auction, the name of the highest bidder, the amount of the winning
bid, and the amount of the deposit paid. The highest bidder needed the
Terms of Sale to complete the settlement of the property transaction
(also called "closing"), which usually occurred within 30
days of the auction. Once the closing was completed, the highest bidder
took title to the property.

6. At the closing on a property purchased at a public foreclosure
auction, the Referee was responsible for obtaining the balance due on
the property from the successful bidder or his assignee. The Referee
was also then responsible for distributing the proceeds to the mortgage
holder in total or partial satisfaction of the judgment. Any money paid
for the property above the amount owed to the mortgage holder represented
a "surplus," which the Referee would then deposit with the
Kings County Clerk. Other lienholders and the foreclosed property owner
could then make a claim on that surplus money.

The Conspiracy's Effect on Interstate Commerce

7. The defendant LEONARD WADLER and his co- conspirators regularly
bought residential properties at foreclosure auctions held at the Kings
County Courthouse.

8. Many mortgage holders involved in the foreclosure auctions in Kings
County were either out-of-state lenders or New York lenders with out-of-state
mortgage processing operations. Consequently, in connection with many
properties purchased at public foreclosure auctions by the defendant
or his co- conspirators pursuant to the conspiracy charged below, money
and documents moved across state lines as part of those transactions.
Those business activities were within the flow of, and substantially
affected, interstate trade and commerce.

SHERMAN ACT CONSPIRACY

9. Paragraphs one through eight are realleged and incorporated by reference
as though fully set forth herein.

10. In or about and between July 1991 and August 1996, both dates
being approximate and inclusive, the defendant LEONARD WADLER and others
entered into and engaged in a combination and conspiracy that illegally
restrained interstate trade and commerce in violation of Section 1 of
the Sherman Act. The charged combination and conspiracy consisted of
a continuing agreement, understanding, and concert of action among the
defendant and co-conspirators, the substantial term of which was to
suppress competition by refraining from full competitive bidding at
certain public foreclosure auctions held in Kings County, in the Eastern
District of New York.

11. It was part of the conspiracy that the defendant LEONARD WADLER
and his co-conspirators agreed not to bid against each other at public
foreclosure auctions at the Kings County Courthouse. As a result, the
conspirators purchased auctioned property at prices lower than would
have resulted from a fully competitive auction, thereby depriving mortgage
holders, lienholders, and property owners of the full value of the auctioned
property.

12. It was further part of the conspiracy that after the public foreclosure
auction, the defendant LEONARD WADLER and his co-conspirators would
hold a second, private auction, open only to the conspirators and generally
conducted by written bid, in which the conspirators would bid to acquire
the foreclosed property at a price higher than the price paid by the
conspirators' designated bidder at the public foreclosure auction.

13. It was further part of the conspiracy that the defendant LEONARD
WADLER and his co-conspirators would award the property to the conspirator
with the highest bid at the private auction. The conspirators would
then divide among themselves the difference between the prices paid
at the public foreclosure auction and the private auction.

14. It was further part of the conspiracy that following the private
auction, the conspirator who was the highest bidder at the public foreclosure
auction would assign his right to purchase the property to the conspirator
who was the highest bidder at the private auction.

15. It was further part of the conspiracy that the conspirator who
submitted the highest bid during the private auction could thereafter:
(1) proceed to close on the property with the Referee at the price set
during the rigged, public auction, or (2) sell his right to close on
the property at the price set during the rigged auction to a third party.

(Title 15, United States Code, Section 1; Title 18 United States Code,
Section 3551 et seq.)